State Climate Policy – Colorado Coalition for a Livable Climate

Prepared by the Fort Collins Sustainability Group (12/31/2014)

Colorado Climate Action Plan: A Strategy to Address Global Warming (November 2007)

  • This document set forth three key roles for State government:
    • Enact “bridge strategies” to reduce GHG emissions immediately before cleaner electricity generation strategies can be implemented,
    • Provide “leadership” so that cleaner electricity generation technologies – including renewable energy (RE) and “clean coal” – can be implemented, and
    • Prepare State to adapt to climate changes that can’t be avoided.
  • Committed Colorado to reducing its GHG emissions 20% below 2005 levels by 2020, and 80% below 2005 levels by 2050.
  • Committed to “leading the establishment” of a carbon credit market – primarily to enable farmers and ranchers to sell carbon credits to power companies.
    • Promised to join the “Western Climate Initiative” if the Federal government didn’t set up a nationwide carbon trading system quickly.
  • Committed to adopting greenhouse gas emissions standards to reduce emissions from passenger vehicles.
  • Committed to establishing a goal of 20% GHG emissions reductions for major utilities by 2020 with respect 2005 levels and to work with smaller utilities to achieve a similar goal.
    • Both expanded use of natural gas to generate power and use of renewable technologies were envisioned as contributing toward these goals.
  • Committed to promoting research and development of clean coal and renewable electric generation technologies.
  • Committed to promoting research and development of ways to reduce methane leaks from oil and gas wells.
  • Committed to initiating a host of programs focused on State government operations, including reducing state government energy use by 20% by 2012, using performance contracting to help reach this goal, and achieving a waste diversion rate goal of 75% by 2020.
  • Committed to reporting on the State’s GHG emissions.
  • Committed to taking steps toward adapting to climate change in the areas of water supply, wildfire risk management, and drought and flood risk management.
  • The authors acknowledged that the Climate Action Plan “does not include the full array of measures we will need to undertake to comprehensively address climate change in Colorado,” and promises “continued analysis and further conversation with Coloradans and others about what additional measures might make sense for Colorado.”
    • In order to facilitate these continued efforts, the report committed to setting up a gubernatorial Climate Advisory Panel by January 2008.

Executive Order D 004 08: Reducing Greenhouse Gas Emissions in Colorado (April 2008)

  • Established GHG emissions reduction goals of 20% below 2005 levels by 2020, and 80% below 2005 levels by 2050 to mitigate impacts to Colorado’s economy.
  • Explicit responsibilities were assigned to two State agencies: the Colorado Department of Public Health and Environment (CDPHE) and the Public Utilities Commission (PUC).
    • The CDPHE was directed to 1) report GHG emissions for major emitters and 2) regulate GHG emissions from passenger motor vehicles, including light trucks.
    • The first update to the initial GHG emissions report was required to come out in 2012, and then every five years thereafter.
    • The PUC was requested to require utilities to submit electric resource plans for meeting GHG reduction goals.
  • Other State agencies were also directed to join in the effort to reduce GHG emissions, including specifically the Department of Natural Resources, The Department of Agriculture, the Governor’s Energy Office, and the Governor’s Office of Policy and Initiatives.
  • The two economic sectors addressed specifically in the Order – electric power and transportation – accounted for only 59% of GHG emissions in 2005.
    • Moreover, the CDPHE was not directed – or able – to regulate emissions from commercial vehicles, and the PUC does not regulate non-investor owned utilities (IOUs).
    • So – the scope of regulation contemplated by Governor Ritter would have addressed well under 59% of Colorado’s 2005 GHG emissions.
    • It was therefore mathematically unlikely that actions taken by either the CDPHE or the PUC within the framework outlined in the Executive Order could have achieved 20% state-wide emissions reductions by 2020 – and mathematically impossible that such actions could have achieved 80% state-wide emissions reductions by 2050.

Colorado Greenhouse Gas Inventory—2014 Update (October 2014)

  • The CDPHE notes that the Inventory fulfills the requirements of Executive Order D 004 08, but does not refer –anywhere in the document – to the GHG emissions reduction goals established therein.
  • The CDPHE used the Environmental Protection Agency’s (EPA’s) State Inventory Tool (SIT) to generate detailed GHG emissions inventories for the period 1990 – 2010 in five year increments, and to project GHG emissions inventories for 2020 and 2030.
  • The Inventory shows that GHG emissions increased from 84 Million Metric Tons (MMT) CO(e) in 1990 to 130 MMT CO(e) in 2010.
    • This is equivalent to a 55% increase over a 20 year period.
  • The Inventory projects that GHG emissions will increase from 130 MMT CO2(e) in 2010 to 143 MMT CO2(e) in 2030.
    • This is equivalent to a 10% increase over a 20 year period.
  • The Inventory also projects that GHG emissions will increase from 123 MMT CO2(e) in 2005 to 134 MMT CO2(e) in 2020.
    • This is equivalent to an 8.9% increase in GHG emissions.
    • Although the CDPHE does not state this, Executive Order D 004 08 called for GHG emissions to DECREASE by 20% over this time period.
  • Two obvious omissions in the projections for 2020 and 2030 are:
    • The impact of Renewable Portfolio Standards (RPSs) for electric cooperatives and municipal utilities, and
    • The Impact of the “Clean Air Clean Jobs” Act of 2010, which will result in the conversion of three electric power plants having a total capacity of 900 MW (6% of the State’s total) from coal to natural gas.
  • A rough order of magnitude calculation suggests that if the two omissions noted above are accounted for, GHG emissions might drop by as much as 4 MMT CO2(e).
    • This would lower 2020 GHG emissions to 130 MMT CO2(e).
    • This would be equivalent to a 5.7% increase compared to the 2005 baseline – still far short of the 20% reduction goal.
  • An additional deficiency in the Inventory is its use of EPA methane emissions factors for oil and gas wells.
    • A recent study published in February of 2014 in the journal Science ( suggests that the EPA emissions factors are approximately 50% too low.
    • This means that GHG emissions from oil and gas wells likely have been and will be higher than those shown in the inventory.
    • We also note that the Inventory does not account for regulations passed in 2014 intended to reduce methane emissions from oil and gas wells. This failure will at least partially compensate for the anticipated increase in methane emissions resulting from the use of the EPA emissions factors.

Concluding Remarks:

The 2007 Climate Action Plan and 2008 Executive Order did not include enough measures to achieve the 2020 or 2050 GHG emissions reduction goals set forth in those documents.  By failing to make any reference whatsoever to those goals in its 2014 Greenhouse Gas Inventory Report, the CDPHE suggests that the effort to achieve them has been abandoned.  And indeed, the numbers show that GHG emissions have been rising since 2005, and will likely continue to rise through 2030 instead of falling.

We believe that the State of Colorado needs to recommit to achieving its GHG emissions goals by developing a comprehensive Climate Action Plan capable of achieving them, and then providing adequate resources to ensure that the measures outlined in that Plan can be fully implemented.  Additionally, we urge the State of Colorado to bring its goals into alignment with those currently under consideration by the City of Fort Collins: 20% GHG emissions reductions by 2020, 80% GHG emissions reductions by 2030, and 100% GHG emissions reductions by 2050 – all with respect to 2005 levels.